Home Depot Inc/The

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Home Depot provides an unusually full picture of its climate-policy advocacy. It names a wide array of specific measures it has worked on, including the Inflation Reduction Act provisions 50122 and 50123, the “Surface Transportation Reauthorization Act of 2021,” the “Energy Savings Through Public-Private Partnerships Act of 2019 (HR 3079/S 1706),” the California small off-road engine (SORE) ban and related battery-powered lawn-equipment voucher programme, Port Infrastructure Development Grant Programs, Florida’s ENERGY STAR Sales Tax Holiday, DOE light-bulb and ceiling-fan efficiency standards, the “Ceiling Fan Improvement Act of 2020 (HR 5758),” and the “Clean Economy Jobs and Innovation Act (HR 4447).” It also spells out how it lobbied and whom it lobbied: it “wrote letters of support for [the] US Department of Transportation PIDP grant program,” “engaged on implementation of [the] voucher program for battery-powered outdoor power equipment” with California regulators, provided “feedback to the Florida Department of Revenue,” and “reviewed [DOE] proposals and provided feedback on timeline for implementation,” among other direct interactions with the US DOE, state energy offices and federal legislators. Finally, the retailer is explicit about the changes it sought, such as “suggested changes to onerous program recording requirements and service center locations/access,” elimination of the “customer affidavit requirement” in Florida’s tax holiday, securing an “appropriate implementation timeline” so retailers could adjust inventory for battery mowers, influencing point-of-sale rebate design under the IRA, and supporting new energy-efficiency standards for large-diameter ceiling fans. By clearly identifying multiple policies, the mechanisms and targets of its engagement, and the concrete outcomes it pursued, the company demonstrates a high level of transparency around its climate-related lobbying.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	The Home Depot discloses a defined structure for managing and overseeing its lobbying, and it shows that climate-related engagements are subject to an internal alignment check, indicating a moderate level of governance. The company states that when engaging on matters related to climate, the Government Relations department reviews policies for alignment with the Companys climate strategy, demonstrating a process aimed at ensuring consistency between climate commitments and advocacy positions. Responsibility for this review sits with our Government Relations department, led by a vice president who reports to our general counsel, while higher-level oversight is provided by The Nominating and Corporate Governance Committee of our Board of Directors, which conducts an annual review of the companys political contributions and payments to trade associations that engage in lobbying activities. The Government Relations team carefully analyzes our engagement activities, trade association partnerships and political contributions, and the company enhances transparency by publishing annual reports of the companys political contributions and the aggregate dues paid to trade associations that engage in lobbying activities. These disclosures indicate clear ownership, recurring monitoring, and coverage of both direct and indirect lobbying channels. However, the company does not disclose any detailed criteria for assessing trade associations climate positions, nor evidence of actions taken to correct or end misaligned memberships, and it has not published a dedicated climate-lobbying alignment report or third-party audit. Consequently, while oversight and review mechanisms exist, the depth and public transparency of climate-specific alignment processes remain limited.	2